Executive summary
Date(s) of inspection: December 2023
Aim of inspection
In accordance with the Office for Nuclear Regulation’s (ONR’s) Operating Facilities Strategy, ONR undertakes a series of planned inspections targeted at fire safety. Fire hazards, if not controlled, can present risks to safety (nuclear and conventional) including common cause failure of safety systems. It is therefore important that the risks from fire are suitably controlled.
The aim of this inspection is to undertake a planned fire safety inspection at Hartlepool to determine the adequacy of implementation of the Licensee’s claims associated with fire prevention and protection to ensure fire (conventional and nuclear) risks are reduced as low as reasonably practicable. This will be achieved by determining how the Hartlepool fire safety cases and risk assessments are implemented to ensure safety functional requirements are delivered.
Subject(s) of inspection
- LC10 - Training - Rating: Not rated
- LC24 - Operating instructions - Rating: Not rated
- LC27 - Safety mechanisms, devices and circuits - Rating: Green
- LC28 - Examination, inspection, maintenance and testing - Rating: Green
- Overall Inspection Rating - Rating: Green
- Regulatory Enforcement - Life Fire Safety - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
This was a planned inspection at the EDF-NGL Hartlepool site. The inspection was undertaken as part of the intervention strategy for Operating Reactors Sub-Division.
Fire hazards, if not controlled, can present risks to safety (nuclear and conventional) including common cause failure of safety systems. It is therefore important that the risks from fire are suitably controlled. This fire safety (FS) inspection at Hartlepool considered both Nuclear and Life Fire Safety (LFS) and was undertaken by the Nominated Site Inspector and fire specialist inspectors to determine whether fire risks at site are suitably controlled. The inspection focussed on areas of the Reactor Building, Turbine Hall, Light Workshop/ Stores / Procurement building, Services Block, Gas Turbine House, Amine Dosing Plant with the greatest nuclear and conventional fire risks respectively.
The FS inspection assessed the implementation of arrangements for managing life fire risks by reviewing compliance against the requirements of the Regulatory Reform (Fire Safety) Order 2005 (FSO) and compliance against the requirement of Licence Conditions LC10 Training, LC27 Safety Mechanisms, Devices & Circuits & LC28 Examination, inspection, maintenance and testing.
The FS inspection assessed the implementation of arrangements for managing life fire risks by reviewing compliance against the requirements of the Regulatory Reform (Fire Safety) Order 2005 (FSO) and compliance against the requirement of Licence Conditions LC10 Training, LC27 Safety Mechanisms, Devices & Circuits & LC28 Examination, inspection, maintenance and testing.
LC10 Training
I sampled the training records for several operators that fulfil roles associated with the fire system. This included, the Fire Systems Co-ordinator (FSC) and the Fire System Engineer with responsibility for fire dampers. I considered that EDF NGL is adequately implementing its training arrangements as staff are either trained or in the process of undertaking the training currently identified as necessary to carry out the fire related aspects of their role. I judge that EDF NGL is adequately implementing its arrangements with respect to Training and award a Green rating for LC10.
LC27 - Safety Mechanisms, Devices & Circuits & LC28 Examination, inspection, maintenance and testing (EIMT)
This part of the inspection was to gain assurance that plant is not operated, inspected, maintained or tested without suitable and sufficient safety mechanisms devices and circuits (SMDCs) being properly connected and in good working order. For this inspection it included sampling elements of the fire detection and suppression system while out on plant and reviewing maintenance records to gain assurance that these systems would protect against fire. I considered the equipment was maintained in accordance with the safety case requirements. I judged that EDF NGL is adequately implementing its arrangements with respect to EIM&T and award a Green rating for LC27 & LC28.
LC24 - Operating Instructions.
This LC was included in the inspection scope but was not rated during this inspection.
Regulatory Reform (Fire Safety) Order 2005 (FSO)
FSO Article 8- Duty to take general fire precautions
I sampled arrangements for compliance with Article 8 by assessment of the preventative and protective measures set out in premises risk assessments and supporting documents, through discussion with EDF NGL personnel and walkdown of buildings and consider these to be generally adequate. I did identify an area that requires further assessment in regards to the provision of fire resisting compartmentation and have raised a Level 4 Regulatory Issue (RI 11877), to monitor this process however this does not affect my overall judgement. I judge that EDF NGL is adequately implementing its arrangements with respect to general fire precautions and award a Green rating for Article 8.
I sampled arrangements for compliance with Article 8 by assessment of the preventative and protective measures set out in premises risk assessments and supporting documents, through discussion with EDF NGL personnel and walkdown of buildings and consider these to be generally adequate. I did identify an area that requires further assessment in regards to the provision of fire resisting compartmentation and have raised a Level 4 Regulatory Issue (RI 11877), to monitor this process however this does not affect my overall judgement. I judge that EDF NGL is adequately implementing its arrangements with respect to general fire precautions and award a Green rating for Article 8.
Article 13 Fire-fighting and fire detection
I reviewed a sample of risk assessments, system health reports, conducted walkdown and discussion and consider that a generally adequate standard of fire detection is in place. I did however identify an area requiring further assessment in regards to the provision of manual call points and I have raised a Level 4 Regulatory Issue (RI 11878) to monitor this process however this does not affect my overall judgement. I judge that EDF NGL is adequately implementing its arrangements with respect to fire-fighting and fire detection and award a Green rating for Article 13.
I reviewed a sample of risk assessments, system health reports, conducted walkdown and discussion and consider that a generally adequate standard of fire detection is in place. I did however identify an area requiring further assessment in regards to the provision of manual call points and I have raised a Level 4 Regulatory Issue (RI 11878) to monitor this process however this does not affect my overall judgement. I judge that EDF NGL is adequately implementing its arrangements with respect to fire-fighting and fire detection and award a Green rating for Article 13.
Article 14 Emergency routes and exits
I reviewed a sample of risk assessments and conducted walkdown of several buildings and consider that the provision of means of escape are generally adequate. I did however identify an area where further assessment is required in regards to the storage of combustibles in a protected stairwell and I have raised a Level 4 Regulatory Issue (RI 11879) to monitor this process however this does not affect my overall judgement. I judge that EDF NGL is adequately implementing its arrangements with respect to emergency routes and exits and award a Green rating for Article 14.
Conclusion
Overall, I found that EDF NGL’s existing arrangements made under LC10, LC27 and LC28 and the requirements of the Regulatory Reform (Fire Safety) Order 2005 are adequate for controlling risks related to fire hazards. From the evidence sampled during this SBI I judge that there were no matters that have the potential to impact significantly on nuclear safety or life safety.
During the inspection I identified some matters of advice for consideration and I have also raised three level 4 Regulatory Issues, however these do not significantly impact on the overall adequate provision of safety.
I have raised a Level 4 Regulatory Issue (RI-11877) to track the assessment of fire resisting compartmentation in the Light Workshop/ Stores / Procurement building area. This forms part of a fleet wide consideration of compartmentation in conventional buildings. I have confidence that this will be managed appropriately and if any corrective actions are required that they will be undertaken as part of this process. I judge that these matters are not of sufficient significance to warrant an amber rating.
I have raised a Level 4 Regulatory Issue (RI-11878) to track the assessment of the the adequacy of the means by which persons would manually raise a fire alarm in the Gas Turbine House. This area is not provided with manual call points, which would be used by persons to raise the alarm in the event of a fire. This Level 4 Issue has been raised in order to require EDF NGL to assess provision and address any shortfall identified. I judge that these matters are not of sufficient significance to warrant an amber rating.
I have raised a Level 4 Regulatory Issue (RI-11879) to track the assessment of the protection of the Reactor Building R1 protected stairwell. The RI stairwell is open to a storeroom containing combustibles This Level 4 Issue has been raised to require EDF NGL to assess the storage of combustibles in the R1 protected stair and to address any deficiencies identified by this assessment. I judge that these matters are not of sufficient significance to warrant an amber rating.
Inspection findings were shared with and accepted by EDF NGL as part of inspection feedback.
Based on my sample and the findings described in this report I consider that EDF NGL adequately demonstrated ownership and implementation of the fire protection systems safety case to ensure and maintain nuclear safety and adequately demonstrated arrangements for Life Fire Safety and on that basis award EDF NGL a Green rating for both elements of the inspection.